20240624IPC to Staff 33-42.pdf

IDAH0
An IDACORP Company
RECEIVED
2024 June 24 AM 9:29
IDAHO PUBLIC
MEGAN GOICOECHEA ALLEN UTILITIES COMMISSION
Corporate Counsel
mgoicoecheaallen(cDidahopower.com
June 24, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-24-11
In the Matter of the Application of Idaho Power Company for a Determination
of 2023 Demand-Side Management Expenses as Prudently Incurred
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Response to the Third
Production Request of the Commission Staff in the above-entitled matter.
Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the attachments
to these requests to the secure FTP site to allow parties to view the requested information
remotely unless otherwise noted in the response. Because certain attachments contain
confidential information, the FTP site is divided between confidential and non-confidential
information.
The login information for the non-confidential portion of the FTP site has been provided to
all parties that have intervened to date. The login information for the confidential portion of
the FTP site has been provided to the parties that have executed the Protective Agreement
in this matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application of Idaho Power Company for Determination of 2023 Demand-Side
Management Expenses as Prudently Incurred
Case No. IPC-E-24-11
The undersigned attorney, in accordance with Commission Rule of Procedure 67,
believes that the attachment to data request no. 42, provided in Idaho Power Company's
Response to the Third Production Request of the Commission Staff dated June 24, 2024,
may contain information that Idaho Power Company and a third party claims constitutes
trade secrets and/or confidential business records of a private enterprise required by law
to be submitted to or inspected by a public agency as described in Idaho Code § 74-101 ,
et seq., and/or§48-801, et seq. As such, it is protected from public disclosure and exempt
from public inspection, examination, or copying.
DATED this 24t" day of June, 2024.
�fA�CI UyJUU�L
Megan Goicoechea Allen
Counsel for Idaho Power Company
CERTIFICATE OF ATTORNEY- 1

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaal len(o-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-24-11
DETERMINATION OF 2023 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) IDAHO POWER COMPANY'S
PRUDENTLY INCURRED. ) RESPONSE TO THE THIRD
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Third Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated June 3, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1

STAFF REQUEST FOR PRODUCTION NO. 33: Please explain if the Company
is considering increasing the funding amounts for any CAP agencies.
RESPONSE TO STAFFS REQUEST FOR PRODUCTION NO. 33:
As an outcome of its last general rate case (IPC-E-23-11) the Company committed
to work with Staff and the Community Action Partnership (CAP) agencies to develop
implementation and ongoing administration details, including funding levels, for its
income-qualified weatherization and low-income education programs.' The Company
expects these discussions to commence in the coming months.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IPC-E-23-11 Stipulation and Settlement at 7
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2

STAFF REQUEST FOR PRODUCTION NO. 34: Please explain if the Company
is considering any other changes to the low-income weatherization programs to increase
program performance.
RESPONSE TO STAFFS REQUEST FOR PRODUCTION NO. 34:
While Idaho Power funds a portion of qualified jobs, the CAP Agencies who
administer the programs follow Idaho State Weatherization Assistance Program ("WAP")
guidelines when qualifying WAQC projects, which are overseen by the Idaho Department
of Health and Welfare ("IDHW"). Idaho Power is in regular communication with IDHW and
is aware of changes being proposed to the method of determining eligible measures from
a savings to investment ratio ("SIR")-based method to a Priority List method. Idaho Power
is prepared to work with the CAP Agencies and IDHW to ensure that Idaho Power low-
income weatherization programs are synced up with these changes to streamline the
process for both the CAP Agencies and Idaho Power.
As part of the discussions described in response to Staff's Request for Production
No. 33, Idaho Power also intends to engage with stakeholders to evaluate the contractual
$6,000 annual average project cost that CAP Agencies currently work toward, to
determine if or how that cap should be changed to keep pace with equipment and other
cost increases.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3

STAFF REQUEST FOR PRODUCTION NO. 35: On Page 10 of the Application,
the Company claims that they are requesting only $3,449,976 in DSM labor to be
collected through the Rider. This amount leaves $175,313 of remaining labor costs that
the Company is not charging to the Rider. Please explain how the Company is paying for
the extra $175,313. In the response, please specify if this amount is being booked below
the line / charged to shareholders, recovered through base rates, or accounted for
through other means.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 35:
Idaho Power recorded the $175,313 of remaining 2023 labor costs to O&M
Account 908 in December 2023 without a corresponding revenue amount. Because this
was an unfunded expense, it resulted in a negative impact to the Company's 2023
earnings.
The response to this Request is sponsored by Robert Everett, Finance Team
Leader II, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF -4

STAFF REQUEST FOR PRODUCTION NO. 36: For promotional and marketing
items in 2023, please answer the following:
i. Please explain what marketing measures the Company claims energy
efficiency savings on;
ii. Please explain the source and basis the Company used to quantify these
savings; and
iii. Please send copies of all advertisements the Company paid for in 2023,
including, but not limited to, all Sponsorship Packages, and any radio or
magazine/newspaper advertisements.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 36:
i. Idaho Power does not claim energy savings on promotional and marketing
items. Giveaway items for which the Company does claim energy savings
fall under the Educational Distribution programs. These giveaway items
include LED night lights, Welcome Kits, and Student Energy Efficiency Kits.
ii. As described on pages 46-47 of the Demand-Side Management 2023
Annual Report, Idaho Power uses a variety of savings sources for the
Giveaway items such as the Regional Technical Forum, third party
evaluators, and calculated savings based on survey information. The
specific sources of savings information can be found on page 16 of
Supplement 1: Cost-Effectiveness.
iii. Please see the attachments provided for this response for copies of all
advertisements. Due to the voluminous nature of the request, the
advertisements/attachments have been provided through the Company's
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5

FTP site.
a. Please note there are numerous copies of print and digital ads as
many different sizes are needed for various publications.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6

STAFF REQUEST FOR PRODUCTION NO. 37: In the Residential New
Construction Program PY2022 Evaluation ("Evaluation"), the evaluator describes how it
verified that reported model output savings and tracked savings matched. The Evaluation
explains that tracking data for the program is retrieved from the regional AXIS database,
reviewed by Company staff, and entered into the Company's database. Evaluation at 4.
Please explain how kWh savings is calculated or otherwise determined and input into the
AXIS database.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 37:
Builders who apply for an incentive in the Residential New Construction Program
are required to contract with a Residential Energy Services Network (RESNET)-certified
rater to ensure the home design will meet program qualifications. The rater works with
the builder from the design stages through project completion; performs the required
energy modeling (REM) using REM/Rate modeling software; performs site inspections
and tests; and enters, maintains, and submits all required technical documentation in the
REM/Rate modeling software and the Northwest Energy Efficiency Alliance (NEEA)-
maintained AXIS database. Raters must model household energy use in accordance with
requirements and guidelines created by the Regional Technical Forum (RTF). A
description of the overall process can be found on the BetterBuilt Northwest website.
https://betterbuiltnw.com/assets/uploads/resources/Performance-Path-Overview-
and-Modeling-for-Utilities-May-2017.pdf
The RTF developed a New Homes Protocol calculator to determine the savings
for each new construction project. The calculator estimates the heating and cooling
energy savings by adjusting the output from the REM/Rate models for each project and
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7

its baseline case. The energy savings for non-heating and cooling measures like water
heaters and appliances are derived from the applicable RTF unit energy savings
workbooks. The savings calculator takes into account the baseline definition for shell and
HVAC for each state based on its codes. AXIS is set up to do this calculation in the back
end.
The protocols and calculator can be found on the RTF's website.
https://nwcounci1.app.box.com/v/NewHomeSProt-v3-1
https://nwcounci1.app.box.com/v/NewHomeSP-CaIc-v3-1
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8

STAFF REQUEST FOR PRODUCTION NO. 38: Please provide an example data
output from the AXIS system.
RESPONSE TO STAFFS REQUEST FOR PRODUCTION NO. 38:
Please see the Confidential attachment to Staff's Request for Production No. 42
for an example of data output from the AXIS system.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9

STAFF REQUEST FOR PRODUCTION NO. 39: Please provide a list detailing if
and what amount (i.e., number of months) of billing data is available for each Residential
New Construction Rebate issued in PY2022 at the time the Evaluation was initiated.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 39:
The Residential New Construction (RNC) evaluation was initiated on June 19,
2023. At that point, 107 out of the 109 service points that received RNC rebates in PY2022
were being actively metered and had billing data available. The table below lists the
number of months of consecutive billing data available for the 109 PY2022 participants
as of June 19th, 2023. The Company notes that having multiple consecutive months of
billing data available does not necessarily mean that the household was occupied during
that period or that the data was representative of regular consumption.
Amount of Billing Data Available Among
PY2022 RNC Participants on June 19th,
2023
# Months Count
NA 2
0 3
1 5
2 9
3 7
4 3
5 2
6 4
7 3
8 4
9 7
10 4
11 9
12 5
13 2
14 2
15 4
16 4
17 7
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10

18 4
19 3
20 0
21 4
22 S
23 4
24 2
>24 1
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11

STAFF REQUEST FOR PRODUCTION NO. 40: Please explain if the Company
has conducted any internal analysis of the Residential New Construction Program using
billing data from the incentivized constructions. If yes, please provide analysis. If not, why
not?
RESPONSE TO STAFFS REQUEST FOR PRODUCTION NO. 40:
The Company has not conducted an internal analysis of the Residential New
Construction program using billing data. Savings for the Residential New Construction
Program are calculated using a standardized regional modeling approach developed by
NEEA and the RTF, as described in the Company's response to Request No. 37.
Evaluation activities such as billing analysis are meant to address specific researchable
issues or objectives. Given that the savings for this program are based on well-founded
and documented modeling practices, the Company has not identified any reasons to
perform internal analysis of billing data within the Residential New Construction Program.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12

STAFF REQUEST FOR PRODUCTION NO. 41: Please provide a timeline for the
PY2022 Evaluation showing start date, important milestones, and end date.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 41:
Idaho Power is interpreting "the PY2022 Evaluation"to refer to the Residential New
Construction impact evaluation of program year 2022. The Evaluation was conducted
along the following timeline:
• RFP Issued — August 11, 2022
• Proposals Received — September 16, 2022
• Evaluator Selected — October 18, 2022
• SOW Executed — May 30, 2023
• Kickoff Meeting — June 19, 2023
• Program Data Requested by Evaluator— June 19, 2023
• Program Data Sent to Evaluator— June 20, 2023
• Draft Work Plan Finalized — July 20, 2023
• Participant Sample Selected — July 26, 2023
• Additional Data Sent to Evaluator— September 5, 2023
• Engineering Desk Reviews Completed — October 20, 2023
• Draft Evaluation Report Received — November 22, 2023
• Final Evaluation Report Received — January 11 , 2024
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13

STAFF REQUEST FOR PRODUCTION NO. 42: Please explain if the REM/Rate
modeling documentation supporting the Residential New Construction Program
incentives provides details on what types of upgrades are being selected to meet energy
savings targets. If so, provide a breakdown of upgrade types selected by participants for
the 2022 and 2023 program years.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 42:
Please see the Confidential attachment provided for this response. The attachment
contains the data output from the AXIS system for all Residential New Construction
Program incentives for the 2022 and 2023 program years. The AXIS output contains the
same data as the REM/Rate Model. The AXIS output provides details on what types of
upgrades are being selected for the Residential New Construction Program. Column A
identifies the program year the savings for each project were claimed; column B contains
the Idaho Power ID number. The output from AXIS begins in column C and contains
nearly 200 datapoints for each home. A complete breakdown of upgrade types selected
by participant would be difficult to summarize, but the Confidential attachment contains
the following information on upgrades if the project contained them:
• Foundation type, area, and U-value
• Ceiling area and R-Value
• Window area and U-value
• Heating system type and HSPF efficiency
• Cooling system type and SEER efficiency
• Water heater system type, capacity, and energy factor
• Clothes washer and dryer efficiency
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14

The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
Respectfully submitted this 24th day of June 2024.
0
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of June 2024, 1 served a true and correct
copy of the within and foregoing Idaho Power Company's Response to the Third
Production Request of the Commission Staff upon the following named parties by the
method indicated below, and addressed to the following:
Adam Triplett Hand Delivered
Deputy Attorneys General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
P.O. Box 83720 FAX
Boise, ID 83720-0074 X Email
adam.triplett(a),puc.idaho.gov
Ed Jewell Hand Delivered
City of Boise City U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 X Email
BoiseCityAttorney(a)_cityofboise.org
ejewell cityofboise.org
Steven Hubble Hand Delivered
Boise City Dept. of Public Works U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 X Email
shubble cityofboise.org
Matthew Nykiel Hand Delivered
Attorney for Idaho Conservation League U.S. Mail
710 N. 6th St. Overnight Mail
Boise, ID 83702 FAX
X Email
matthew.nykielC@.gmail.com
Brad Heusinkveld Hand Delivered
Idaho Conservation League U.S. Mail
710 N. 6th St. Overnight Mail
Boise, Idaho 83702 FAX
X Email
bheusinkveld(a)_idahoconservation.org
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16

F. Diego Rivas Hand Delivered
NW Energy Coalition U.S. Mail
1101 8th Ave Overnight Mail
Helena, MT 59601 FAX
X Email
diego nwenergy.org
Ken Robinette Hand Delivered
South Central Community Action U.S. Mail
Partnership Overnight Mail
550 Washington Street South FAX
Twin Falls, ID 83303 X Email
ken _sccap-id.org
a4lw
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17